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Teton to Snake Fuels Management Project

Resource Report – Special Areas

Prepared by:

Linda Merigliano

Recreation, Wilderness Program Manager

Jackson Ranger District, BTNF

November 21, 2011

Updated May 25th, 2012

Updated October 8th, 2014

Updated July 20th, 2015

Updated August 26, 2016

Teton to Snake Fuels Management Project Special Areas Report

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A. Introduction

This analysis focuses on disclosing the consequences of implementing three alternatives for

proposed fuel treatments on special area designations within or near the Teton to Snake

project area. Special areas included in this analysis include the Palisades Wilderness Study

Area (WSA), the Munger Mountain inventoried roadless area (IRA), the Phillips Ridge

inventoried roadless area (IRA), the Snake River Wild and Scenic River corridor, and the

Jedediah Smith Wilderness. Proposed treatments are located within the WSA and IRAs, thus

the effect on these designations are the focus of this analysis. For the WSA, this analysis is

intended to provide information on two key questions: (1) what is the effect on the area’s

potential for inclusion in the National Wilderness Preservation System and, (2) what is the

effect on “presently existing wilderness character” where “presently existing” is defined by

the character that existed in 1984 when the area received Congressional protection. For the

IRAs, this analysis is intended to provide information on the effect of the proposed treatments

on the area’s wilderness attributes. National Forest Service policy, Forest Service

Intermountain Region analysis guidance, current scientific research, and previous

environmental analyses are used to structure and inform this analysis.

Overview of Issues Addressed

Issues to be Addressed

1. Effect on Wilderness Study Area

Public concern exists about the proposed fuel treatments within the Palisades

Wilderness Study Area. Of particular concern are the proposed mechanical treatments.

The expressed concern is that the treatments represent a human manipulation of

wilderness that violates the legal protection given to the area, will reduce the potential

of the area being designated as Wilderness in the future, will establish a precedence for

continued vegetation manipulation, and will not substantially change how fires are

managed in the future. In summary, there is concern that the proposed treatments

would impair the character of the Palisades WSA and reduce its potential for future

designation with no clear benefit to wilderness values.

2. Effect on Inventoried Roadless Areas

Public concern exists about proposed treatments within inventoried roadless areas. The

expressed concern is that the treatments will impair the wilderness attributes of the

areas and reduce the likelihood that these areas could be recommended for Wilderness

designation.

No issues or concerns were raised either internally or through public scoping about the effect

of the proposed treatments on designated Wilderness or designated Wild and Scenic River

corridors. These special designations are located outside of the project area. Potential effects

on these areas will be briefly discussed but are not analyzed in detail.


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Issue Indicators

1. Effect on Wilderness Study Area

a. Acres of mechanical treatment within the Wilderness Study Area

b. Acres of prescribed burning within the Wilderness Study Area

c. Effect on potential for inclusion of the WSA in the National Wilderness

Preservation System

d. Effect on “presently existing wilderness character” with focus on the untrammeled

and natural qualities

For the WSA, Congressional direction found in the Wyoming Wilderness Act (PL 98-550)

requires the Forest Service to administer the area to “maintain its presently existing

wilderness character and potential for inclusion in the National Wilderness Preservation

System”. The effects of the proposed fuel treatment would be considered significant if the

treatments caused a decline in the area’s wilderness character over the long run compared

to the character that existed in 1984 or if the treatments reduced the potential of the area to

be designated as Wilderness based on wilderness inventory criteria (FSH 1909.12, chapter

70).

2. Effect on Inventoried Roadless Areas

a. Acres of mechanical fuel treatment within the Inventoried Roadless Area

b. Acres of prescribed burning within the Inventoried Roadless Area

c. Miles of road maintained within Inventoried Roadless Area

d. Effect on wilderness attributes with focus on apparent naturalness and natural

integrity

The Forest Service has established national direction and federal regulations for the

interim management of IRAs. The Code of Federal Regulations found at 36 CFR 294.12

and 294.13 establishes prohibitions on road construction and reconstruction and on timber

cutting, sale, or removal. National direction for IRAs is also found in Secretary of

Agriculture Memorandum 1042-156 issued in May 2011 and the Forest Service Chief’s

letter of June 10, 2011. The effects of the proposed fuel treatment would be considered

significant if the treatments were inconsistent with national direction or federal

regulations.


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B. Affected Environment or Existing Conditions Palisades Wilderness Study Area

The Palisades Wilderness Study Area is approximately 134,500 acres based on the map of

record (Map 1). Approximately 24 percent of the Teton to Snake fuel treatment project

area is located within the Palisades Wilderness Study Area. The legislative direction for

the wilderness study area states that the Forest Service “shall administer the area so as to

maintain its presently existing wilderness character and potential for inclusion in the

National Wilderness Preservation System.”

Four qualities of wilderness character based on the definition of wilderness in the 1964

Wilderness Act are used to organize and present information in this analysis. For the

Palisades Wilderness Study Area, the existing conditions described below are known.

1. Untrammeled quality – Fires have been effectively suppressed since the 1950s.

Historic fire occurrence data shows that over 200 fires have burned within the project

area since 1953 with an average of 3.3 fires per year, all of which were suppressed.

Between 2008 and 2011, there was again an average of four fires per year, all of which

were suppressed. Outside of the project area, a few fires occurring on the Caribou-

Targhee and Bridger-Teton National Forest within the Palisades have recently been

allowed to play their natural role. No prescribed burning has been conducted. Other

modern human interventions include the introduction of non-native mountain goats in

the early 1970s and timber harvest which is described under the natural quality. Other

natural processes including landslides and the free-flow of water within the area are

intact and retain high natural integrity.

2. Undeveloped – Much of the country is considered too rugged and geologically unstable

(e.g. landslides) to lend itself to development, thus the majority of the area retains its

remote and undeveloped feel. However, some old timber and 4WD roads are evident

and there are some physical developments that pre-date passage of the Wyoming

Wilderness Act but are within the boundary for the wilderness study area (e.g.

roads/trailheads, power lines, electronic site, recreation residences). Exploratory oil

and gas seismic work occurred in the 1980s but signs and seismic line have mostly

been removed. Constructed facilities for domestic livestock grazing and other activities

are minor and primitive in nature. Approximately 150 miles of non motorized trail

provide access throughout the area, the vast majority of which is primitive in nature

with few signs. The only exception is the Teton Pass area where trails and signs are

maintained to a higher standard. The area was closed to wheeled motor vehicle use in

2000 due to rapidly expanding motor vehicle impacts beyond what existed in 1984

(with exceptions authorized only for emergencies and permitted use). Implementation of

vehicle closures is on-going. While illegal wheeled motor vehicle use has been greatly

reduced, some violations do occur. Chainsaws are used intermittently to clear trails of

downfall.

3. Natural – The area is noted for its rugged terrain, scenic and watershed values

(containing many small tributaries to the Snake River including a designated Wild and

Scenic river – Wolf Creek). The area also contains habitat for elk, deer, moose,


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wolves, wolverine, and bears. Important elk calving areas exist within the area and the

area is considered an important migration corridor for many species. A variety of plant

communities and vegetation types exist in the area, including some that are not

common in the Bridger-Teton National Forest (curl-leaf mahogany, bigtooth maple).

Noxious weeds are present in localized disturbed areas but are not widespread. A rare

plant inventory conducted in the Snake River Canyon found some sensitive plants

(Payson’s milkvetch) so it is possible that such plants would be present in the adjacent

wilderness study area. Some alteration of native vegetation has occurred; for example,

localized areas of pure wyethia stands (mule’s ear) on old sheep beds. Historic logging

occurred to provide wood for local homesteads, notably in the Teton Pass and

Mosquito Creek area but the forest canopy has not been altered. In the late 1970s and

early 1980s, commercial timber harvest occurred in the Mosquito Creek and North

Fork Fall Creek drainages. A review of Forest Service timber harvest records and maps

show a total of 1,923 acres of clear-cut and partial cut timber harvest occurred within

the Teton to Snake project area during the 1970s and early 1980s. Of these harvest

areas, approximately 483 acres are located within the boundary for the wilderness

study area (Map 2). These harvest acres are now fully regenerated although the new

trees are obviously younger compared with the surrounding landscape.

4. Outstanding opportunities for solitude or primitive, unconfined recreation - The area

provides high potential for solitude, primitive recreation, and challenge by virtue of its

size, dissected topography, and vegetative screening. The wild character of the area

supports multi-day trips including outfitted pack trips, hunting, and backpacking.

Although the area is close to Jackson and some trailheads originate along paved

highways, it receives low to moderate levels of use throughout most of the area. Minor

congestion and conflict can occur during the fall hunting season and in the more heavily

used Teton Pass area. The area is closed to summer wheeled motorized use. Mountain

bike use is allowed on existing trails but is concentrated primarily on a few trails in the

Teton Pass area. Snowmobiling and limited guided heli-skiing occur during the winter

months.

Munger Mountain Inventoried Roadless Area #03009

Approximately 14 percent of the Teton to Snake fuel treatment project area is within the

Munger Mountain Inventoried Roadless Area (Map 3). This inventoried roadless area is

estimated to contain 12,900 acres based on the Roadless Area Review and Evaluation

(RARE II). At that time, the Munger Mountain area was not recommended for wilderness

designation since it did not receive high public interest and was found to be deficient in

some wilderness attributes, notably the opportunity for solitude. However, the area

retains other wilderness attributes and remains on the list of roadless areas. Unlike the

wilderness study area, inventoried roadless areas are not managed to maintain

“wilderness character”, however proposed projects in these areas must be evaluated as to

their potential effects on the area’s wilderness attributes. These attributes include natural

integrity, apparent naturalness, remoteness, solitude, primitive and unconfined recreation,

special features, and manageability.


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The following conditions characterize the existing environment in the Munger Mountain

Inventoried Roadless Area:

1. Natural Integrity and Apparent Naturalness – Munger Mountain is characterized by

extensive aspen communities resulting from fire that burned much of the area in the

1930s. There is a resident elk population and the aspen and forb community is

important for raptors, owls, and migrating songbirds. The area has a long history of

grazing which has altered the native vegetation and steambanks in localized areas.

Noxious weeds are considered a problem throughout the area including a patch of leafy

spurge which is treated annually. Fire starts are routinely suppressed due to the small

size of the area and proximity to residential development to the east, west, and north.

Some past timber harvest and old roads are evident within the area. Within the Teton to

Snake fuel treatment project area, a total of 84 acres of clear-cuts and partial cut timber

harvest dating from the late 1970s and early 1980s occurred within the inventoried

roadless area.

2. Remoteness and Solitude – Munger Mountain does not retain a remote feel due to its

relatively small size and easy access. The area supports diverse day use opportunities

but camping and multi-day trips rarely occur. The area receives moderate use, notably

on the west side where a well- developed trail system is in place. On this trail system,

use is increasing and it is common to encounter other groups but congestion and

conflict is not considered to be a major problem.

3. Primitive and unconfined recreation – Up until January 2009, the Munger Mountain

area was open to unrestricted summer wheeled motorized use. At that time, only one 3-

mile system trail was present. However, due to cattle and unrestricted horse riding,

hiking, mountain biking, and motorcycle and ATV use, the area developed an extensive

network of non-system, user-created trails. In January 2009, a Record of Decision was

signed restricting summer wheeled motorized use to designated trails. Motorcycles

were the only motorized use allowed and the season of use was limited to July 1st –

September 9th annually. ATVs and full-size vehicles are not permitted. The newly

designated 18- mile trail system has been mostly reconstructed with extensive signing

in place and the area is becoming increasingly popular for all the permitted uses:

hiking, mountain biking, horse riding, motorcycle riding, and fall hunting.

4. Special Features – A fire lookout was located on the summit of Munger

Mountain, however the tower structure no longer exists; concrete and cables are

all that remain.

5. Manageability – Munger Mountain is generally not considered large and remote

enough to be managed as wilderness, especially in comparison with other nearby

wildernesses and roadless areas on the Bridger-Teton National Forest.

Phillips Ridge Inventoried Roadless Area #03903

Approximately 12 percent of the Teton to Snake fuel treatment project area is within the

Phillips Ridge Inventoried Roadless Area (Map 4). This inventoried roadless area is

estimated to contain 9,900 acres based on the Roadless Area Review and Evaluation


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(RARE II). The following conditions characterize the existing environment in the Phillips

Ridge Inventoried Roadless Area:

1. Natural Integrity and Apparent Naturalness – The Phillips Ridge area is

characterized by a mix of aspen and sub-alpine environments. It is part of the Teton

Range and forms the spectacular western backdrop of Jackson Hole. Sheep grazing

occurred in the area until the 1990s but vegetation alteration is not evident. Some old

roads are evident in the vicinity of the powerline road but they do not extend far into

the inventoried roadless area which is located north and west of the power-line road.

However, the powerline corridor is quite visible from many view points within the

inventoried roadless area. Within the Teton to Snake fuel treatment project area, a total

of 72 acres of past clear- cut or partial-cut timber harvest occurred within the

inventoried roadless area.

2. Remoteness and Solitude –It is very common to encounter other groups within the

Phillips Ridge Inventoried Roadless Area, limiting opportunities for solitude.

Wyoming State Highway 22 (Teton Pass) offers easy access to developed trailheads,

thus the vast majority of the use is for day trips and there is not a high sense of

remoteness. Backpacking trips do sometimes originate from this area to access the

Jedediah Smith Wilderness on the Caribou-Targhee National Forest west of the

inventoried roadless area.

3. Primitive and unconfined recreation – The Phillips Ridge area contains five heavily

used trails including Ski Lake, Phillips Pass, Phillips Canyon, and portions of the

Arrow and Phillips Ridge trails. These trails are managed for hiking, horse riding,

and mountain biking with some separated use; bikes are not allowed on the Ski Lake

and Phillips Pass trails, and horses are not allowed on the Arrow trail. An outfitted

camp associated with Trail Creek Ranch operated for many years near Phillips Pass.

Outfitted trips still occur but use is very limited.

4. Special Features – Ski Lake and the extensive wildflower displays in the meadows

are special attractions for recreation users. There is a prehistoric obsidian quarry in

the area and an old trapper cabin near Phillips Pass.

5. Manageability – Interest by wilderness proponents in the 1970s and early 1980s was

primarily related to the area’s common boundary with the West Slope of the Tetons,

however this area was not included with designation of the Jedediah Smith Wilderness.

C. Management Framework

Wilderness Study Area

Legislative Direction

The Wyoming Wilderness Act (PL 98-550) passed Congress on October 30, 1984. The

purpose of the Act was to – “designate certain National Forest System lands for inclusion in

the National Wilderness Preservation System in order to preserve the wilderness character of


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the land and to protect watersheds and wildlife habitat, preserve scenic and historic resources,

and promote scientific research, primitive recreation, solitude, physical and mental challenge,

and inspiration for the benefit of all of the American people”.

The Palisades area was designated a “Study Area” due to its potential for oil and gas

resources. Within the Forest Service, a Wilderness Study Area (WSA) is a Congressional

designation for an area that is not included in the National Wilderness Preservation System,

but receives protections while it is being studied for possible future designation. Although a

WSA is not subject to all of the requirements of the Wilderness Act, the area must be managed

in accordance with legislative direction in the Wyoming Wilderness Act until Congress

decides whether or not to include it in the Wilderness System. Legislative direction for this

area includes the following:

1. The Secretary of Agriculture “shall administer the area so as to maintain its presently

existing wilderness character and potential for inclusion in the National Wilderness

Preservation System”.

2. The Secretary of Agriculture, “shall, upon revision of the initial land management

plans for the Bridger-Teton and Targhee National Forests, review the Wilderness Study

Areas as to their suitability for preservation as wilderness”. This time period was

considered sufficient for leasees to either prove or disprove the USGS survey

assessment of the area’s high potential for oil and gas. (Note: the BTNF Forest Plan

revision effort has not yet begun.)

The requirement to maintain “presently existing wilderness character” is a central concept

for stewardship of the Palisades Wilderness Study Area. Wilderness character is not

explicitly defined in either the 1964 Wilderness Act or the Wyoming Wilderness Act

(Section 203 of the Wyoming Wilderness Act ties administration of areas designated by the

Act back to the provisions of the Wilderness Act of 1964). Wilderness character is a

holistic concept based on the interaction of (1) biophysical environments primarily free

from modern human manipulation and impact, (2) personal experiences in natural

environments relatively free from the encumbrances and signs of modern society, and (3)

symbolic meanings of humility, restraint, and interdependence that inspire human

connection with nature. Taken together, these tangible and intangible values define

wilderness character and distinguish wilderness from all other lands. (Landres et al. 2015).

The more tangible aspects of wilderness character are embodied in the “Definition of

Wilderness” found in section 2c of the 1964 Wilderness Act.

The Wilderness Act also contains a number of special provisions for stewardship of

Wilderness. Most relevant to the proposed fuel treatments is the provision that “such

measures may be taken as may be necessary in the control of fire, subject to such conditions

as the Secretary deems desirable” (1964 Wilderness Act, Section 4d(1)). This provision does

not negate the requirement to still maintain wilderness character but does acknowledge that

some flexibility in managing fire may be necessary.

The Healthy Forests Restoration Act of 2003 permits use of a streamlined administrative

review process for hazardous fuel reduction projects that meet particular criteria on Federal

land. Under this authority, fuel reduction projects cannot be considered in Wilderness or

Wilderness Study Areas. The Teton to Snake fuel treatment project is not being proposed


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under this authority, thus the standard environmental administrative review process is being

used and projects within wilderness study areas can be considered.

Bridger-Teton National Forest Plan Direction – Management Prescription 6S

“The Wilderness Study Areas will be managed to protect long-term wilderness attributes. No activities

will be allowed that will jeopardize the eligibility of the WSAs for future Congressional designation as

Wilderness. Existing uses of the WSAs, such as snowmobiling and mountain biking, will be allowed to

continue”.

The BTNF Forest Plan identifies no silvicultural opportunities within DFC 6S but is silent on

fuel treatment activities.

Forest Service National Policy

National policy for management of wilderness study areas or recommended wilderness is

not available. Wilderness study areas are not managed the same as designated wilderness,

since some activities prohibited in Wilderness are allowed in WSAs, however

Congressional requirements for the area must be followed. With respect to resource

management activities such as fuel treatments, the activity must be evaluated to show how

it helps maintain wilderness character and maintains the area’s potential for inclusion in the

National Wilderness Preservation System.

For proposed fuel treatment projects, national policy direction for managing fire in designated

Wilderness is particularly relevant (USDA FSM 2324.2). This direction contains the following

objectives:

1. Permit lightning caused fires to play, as nearly as possible, their natural ecological role

within wilderness.

2. Reduce, to an acceptable level, the risks and consequences of wildfire within wilderness or

escaping from wilderness.

Forest Service managers may ignite a prescribed fire in wilderness to reduce unnatural

buildups of fuels only if necessary to meet at least one of the wilderness fire management

objectives listed above and if all of the following conditions are met:

a. The use of prescribed fire or other fuel treatment measures outside of wilderness

is not sufficient to achieve fire management objectives within wilderness.

b. An interdisciplinary team of resource specialists has evaluated and

recommended the proposed use of prescribed fire.

c. The interested public has been involved appropriately in the decision.

d. Lightning-caused fires cannot be allowed to burn because they will pose serious

threats to life and/or property within wilderness or to life, property, or natural

resources outside of wilderness.

(Forest Service Manual 2324.2)

For the Teton to Snake proposed fuel project, an interdisciplinary team of resource specialists

reviewed this direction and found that all four conditions apply.

National policy direction does exist for evaluating an area’s potential for inclusion in the

National Wilderness Preservation System (USDA-Forest Service Handbook 1909.12). The

process to develop a recommendation for wilderness as part of the Forest Plan Revision


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includes three steps – inventory, evaluation, and analysis. To meet the Wyoming Wilderness Act

direction to maintain the area’s potential for inclusion in the National Wilderness Preservation

System, the inventory criteria found in FSH 1909.12 must be met. These criteria include the size

of the area and limitations on road improvements. Other improvements may or may not exclude

an area for inclusion as potential wilderness depending on whether the improvement or

evidence of past human activity is not “substantially noticeable in the area as a whole”.

Relevant to the proposed fuel treatment project, an area would be eligible for wilderness if

“vegetation treatments are not substantially noticeable”. Obviously, what is considered

“substantially noticeable” is a matter of perception and is evaluated for the area as a whole, not

acre by acre. The inventory process involves considerable public dialogue, drawing on

experience from other National Forests undergoing Forest Plan Revision.

Palisades Wilderness Study Area Boundary

In response to the proposed Teton to Snake fuel treatment project, a concern emerged in

March 2012 regarding the validity of the map used to depict the Palisades WSA boundary. At

issue was concern that the existing map for the WSA did not meet the requirements of Section

303 of the Wyoming Wilderness Act and subsequent direction from the Congressional

committee. As a result, the District Ranger decided to put the Teton to Snake project on hold

to allow time to research and resolve the boundary issue. On June 17, 2014, the Forest Service

Washington Office transmitted the Palisades final map and certified boundary description to

the appropriate Congressional committees. The map of record is archived and can be found at

http://data.fs.usda.gov/geodata/other_fs/wilderness/stateMap.php?stateID=WY. Map 1 displays the

Palisades WSA map and it is this boundary which is now being used for the Teton to Snake

fuel treatment project. The entire project record for the Palisades WSA boundary is archived

and available separately from the Jackson Ranger District.

Summary: Legislative direction and national policy are silent on fuel treatment projects within the Palisades WSA. Additionally, while there are an increasing number of court cases involving Wilderness Study Areas, none of these cases involve proposed fuel treatment projects. Additionally, there is no evidence that fuel treatment projects have prevented an area from being designated as Wilderness (personal conversations with wilderness specialists within the Forest Service 2011-2014 and preliminary information regarding disposition of other WSAs – see GAO Report. Status and Uses of Wilderness Study Areas, September 1993). The key requirements are (1) to ensure the proposed treatments are the minimum “necessary” to control fire and reduce the risk of fire burning out of the WSA, and (2) to analyze and disclose the effects of the proposed treatments on the potential inclusion of the area in the NWPS and on the area’s presently existing wilderness character. The Office of General Counsel was consulted on this direction for addressing proposed fuel treatment projects in the WSA.

Inventoried Roadless Areas

Activities involving road construction or reconstruction and timber cutting within Inventoried

Roadless Areas are subject to the requirements of the 2001 Roadless Rule. Consistent with the

Rule, the Code of Federal Regulations establishes prohibitions on road construction and

reconstruction and on timber cutting, sale, or removal (36 CFR 294.12 and 294.13).

Prohibitions pertinent to the Teton to Snake fuel project include:

http://data.fs.usda.gov/geodata/other_fs/wilderness/stateMap.php?stateID=WY


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294.12 Prohibition on road construction and road reconstruction in inventoried roadless areas.

(a) A road may not be constructed or reconstructed in inventoried roadless areas of the National Forest

System, except as provided in paragraph (b) of this section.

294.13 Prohibition on timber cutting, sale, or removal in inventoried roadless areas.

(a) Timber may not be cut, sold, or removed in inventoried roadless areas of the National Forest

System, except as provided in paragraph (b) of this section.

(b) Notwithstanding the prohibition in paragraph (a) of this section, timber may be cut, sold, or

removed in inventoried roadless areas if the Responsible Official determines that one of the following

circumstances exists.

(1) The cutting, sale, or removal of generally small diameter timber is needed for one of the following

purposes and will maintain or improve one or more of the roadless area characteristics

(ii) To maintain or restore the characteristics of ecosystem composition and structure, such as to reduce

the risk of uncharacteristic wildfire effects, within the range of variability that would be expected to

occur under natural disturbance regimes of the current climatic period;

The Intermountain Region of the Forest Service has prepared guidance for analyzing the

effects of proposed projects on Inventoried Roadless Areas. “The standard of analysis for

impacts to Inventoried Roadless areas mandates that the potential adverse effects to

wilderness potential be described. This is usually accomplished by discussing the effects to

the wilderness attributes of the Inventoried Roadless Area” (USDA 2008).

Bridger-Teton National Forest Plan Direction

Munger Mountain IRA – Management Prescription 12

Most of the Munger Mountain IRA is in Management Prescription 12 which focuses on

providing important habitat for big-game such as calving and security areas. Fire direction

within this management prescription emphasizes preservation and enhancement of habitat,

particularly through prescribed fire.

Phillips Ridge IRA – Management Prescription 2B Most of the Phillips Ridge IRA is in Management Prescription 2B which focuses on maintain or enhancing dispersed recreation opportunities. Fire direction within this management prescription emphasizes a slightly modified landscape.

D. Environmental Consequences

Methodology

To analyze the effects of the proposed fuel treatment project on the Palisades Wilderness

Study Area, two key aspects of the issue are addressed.

1. What is the effect of the proposal on the potential of the area for inclusion in the

National Wilderness Preservation System?

2. What is the effect of the proposal on wilderness character and how does this compare

to the wilderness character that existed in the Palisades in 1984 when the area was

designated?


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To address question 1, the wilderness inventory and evaluation language found in Forest

Service Handbook 1909.12 is used to structure the analysis.

To address question 2, the analysis is structured around disclosing the negative and positive

effects of proposed treatments on the four tangible qualities found in the definition of

Wilderness from the 1964 Wilderness Act.

Additionally, in accordance with the Wilderness Act, there is a need to ensure the proposed

treatments are the minimum necessary to control fire and reduce the risk of fire burning out of

the WSA onto adjacent lands. What is considered the “minimum necessary” in the context of

fire comes down to acceptable risk. Differing levels of risk associated with fire burning out of

the WSA onto adjacent lands is reflected in the three alternatives addressed in the FEIS.

To analyze the effects of the proposed fuel treatment project on Inventoried Roadless Areas,

the negative and positive effects of proposed treatments on wilderness attributes are disclosed

with focus on the effects to natural integrity and apparent naturalness. Due to the prohibitions

on road construction and timber cutting, the analysis discloses miles of road maintenance as

well as the number of acres of mechanical fuel treatment. The Teton to Snake fuel project does

not include any road construction or reconstruction in the WSA or in the IRAs.

Incomplete and Unavailable Information

Detailed baseline conditions were not documented when the Palisades WSA was designated

in 1984, but information can be derived particularly for the untrammeled and natural qualities

which are most relevant to this project.

Spatial and Temporal Context for Effects Analysis The spatial context for analyzing direct and indirect effects of the proposal on the Palisades

Wilderness Study Area is the designated wilderness study area. For the inventoried roadless

areas, the direct and indirect effects of the proposal are the inventoried roadless area

boundaries. This spatial and temporal scale is appropriate to determine effects because the

indirect and indirect effects as measured by the analysis indicators are site-specific and

reflect the unique management direction for these specific areas. The effects do not extend

beyond the boundaries of the wilderness study area or inventoried roadless areas.

The temporal context for analyzing direct and indirect effects of the proposal is estimated to

be 1-3 years for near-term effects associated with mechanical treatments and 5-10 years for

effects associated with prescribed burning. This time period is considered sufficient to fully

implement the project. However, to adequately assess whether the treatments have resulted

in changing the response to wildfires, data will need to be compiled over a longer time

period (20 years or more) to avoid the yearly fluctuations in fire response due to drought

cycles and regional and national fire preparedness levels.


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Alternative 1 – No Action

Direct and Indirect Effects of Taking No Action

Under Alternative 1, there would be no fuel treatment (i.e. no mechanical treatments, no prescribed burning, and no snag removal) conducted in the Palisades WSA or in the two IRAs and no associated road work or fire control line construction.

Palisades Wilderness Study Area Effects

Effect on potential for future designation as Wilderness: Implementing the no-action

alternative would have no effect on the area’s potential for future designation as wilderness.

The criteria for eligibility are not as restrictive as the criteria for stewardship after

designation. There would be no effect on any of the inventory criteria used to determine

whether to include areas for consideration as wilderness. However, fires would continue to

be suppressed in much of the area, particularly in the area that is part of the wildland-urban

interface fire protection zone. This would be a factor during the evaluation phase of the

process, when considering the effect of adjacent lands on the ability to preserve wilderness

characteristics. Fire suppression would not prevent the area from being included in the

inventory and thus, would not prevent the area from being eligible for wilderness designation.

Effect on “presently existing wilderness character”: In comparison with other alternatives,

the no-action alternative would have the least noticeable effect on “presently existing

wilderness character”. This does not mean that there would be no effect. All alternatives,

including no action, have some negative effects on wilderness character. In terms of the

“untrammeled” quality, continued fire suppression means that managers would be

implementing suppression actions every year that would interfere with natural fire processes.

However, fire suppression is generally viewed by the public as less manipulative than actions

to mechanically treat fuels, because the degree of upfront human control is less. However,

given that there likely would be more fire on the landscape in the future in response to a

changing climate, the need to intervene with fire processes would become a more common

occurrence as would the need to use more aggressive suppression tactics due to the higher

potential of forest fuels to produce crown fires and high flame lengths (Riginos and

Newcomb 2015, Westerling, et al. 2011).

In terms of the “natural” quality, the no-action alternative would result in the greatest long-

term adverse effect due to the combination of fire suppression and suppression activities.

However, the precise magnitude of this effect is unknown due to the difficulty of

determining plant community development in a dynamic system. Plant and animal

communities in the wilderness study area have evolved with fire and suppressing lightning-

ignited wildfires removes one of the most important natural processes known to occur in

this area. Fire suppression is anticipated to have the greatest effect on moderate-sized, mixed

severity fires, i.e. those that would grow to a much larger size with no human interference

(refer to Fire and Fuels analysis in this chapter). These fires are the ones most effectively

suppressed for the past 60 years. New studies are helping quantify the hidden consequences

of fire suppression in protected areas by displaying where fires would have spread if they

had been allowed to burn under known weather and fuel conditions. These studies show

that past fires have a major effect on how and where future fires burn. In some cases fire

spread is curtailed by previously burned areas and some ignitions would not have spread at


14

all (Miller 2011). A similar study was done specifically for the Palisades Wilderness Study

Area to model fire growth from lightning ignitions under three different weather scenarios.

Under low severity burning conditions (50th percentile burning index), the model reveals

that 108 natural ignitions between 1971 and 2010 would have burned an estimated 53,820

acres within the wilderness study area (Rojo 2012). To account for potential overlap in

burned acres, a conservative estimate suggests at least half of these acres would have

actually burned (Johnston 2012). In reality, less than 5,000 acres burned during that time

period most of which was in the Green Knoll fire. Maps 5 and 6 show a comparison

between historic fires since 1931 versus what would have burned between 1971 and 2010

under a low severity burning index if fires had been allowed to operate freely. With

continued fire suppression into the future, the effects of suppression would become more

pronounced across all plant communities, favoring subalpine fir and other late seral species

at the expense of aspen, forbs, and other early seral species. Fuel loading would also build

over time creating the potential for a greater number of large fires when conditions are

right. Suppression actions associated with large fires are more intense and heavy-handed

which would cause localized effects associated with hand and bulldozer fire lines, spike

camps, helispots, and use of retardant. For example, controlling the Green Knoll fire resulted

in 16.24 miles of bulldozer line, 8 miles of which was within the WSA (Map 7). As noted in

the Fire and Fuels analysis, approximately 42 percent of the defense zone could generate

flame lengths over 4 feet making it necessary to use mechanized equipment, including

aircraft, for suppression activities. In addition, approximately 11 percent of the defense zone

could experience active crown fire, making control efforts less effective and more hazardous

to firefighters and the public. In conclusion, the natural quality would not be noticeably

degraded in the short-term due to lack of any new disturbance in proposed areas of

mechanical fuel treatment. However in the long-term, the natural quality would be adversely

affected by localized suppression activities and by removing fire’s ability to naturally shape

plant and animal communities. In terms of the “undeveloped” quality and the “solitude and

primitive, unconfined recreation” quality, implementing the no-action alternative would

have no effect on presently existing conditions.

Inventoried Roadless Area Effects

The No Action Alternative would have no effect on wilderness attributes in the IRAs in the short-term but would affect the natural integrity attribute over time. Similar to the Palisades WSA, the lack of fuel treatments would not affect natural integrity in the short-term. However, the effect would become more pronounced in the long-term as fire suppression continues and suppression activities become more frequent or heavy-handed. There would be no effect on other wilderness attributes.

Cumulative Effects

Because no actions are proposed under this alternative, there would be no cumulative effects associated with past, present, and reasonably foreseeable actions in or near the Teton to Snake fuel treatment project area. Trends associated with long-term fire suppression effects as discussed above would continue.


15

Alternative 2 – Modified Proposed Action Under alternative 2, there would be 825 acres of mechanical fuel treatment in the Palisades

Wilderness Study Area (0.6 percent of the area) Specific treatment units include portions of

Powerline Unit 1, Recreation Trail Units 1, 35, 6, and 7, Singing Tree Units 1, 2 and 4,

Highland Hills Unit 1, Red Top Units 1, 3 and 5, and the Trails End Unit. All of the proposed

mechanical treatments within the wilderness study area would be noncommercial thinning

and would consist of cutting smaller trees (up to 9 inches dbh) and limbing branches on

larger trees to reduce the potential of fire spreading into tree crowns.

Chainsaws would be used for cutting but no ground-based machinery would be used. No

permanent or temporary roads would be constructed or reconstructed. The cut trees would

be left on-site with no removal for commercial use. The expected visual outcome is

displayed in figure 7. Where the thinning creates low amounts of woody debris, branches

would be cut off and the debris scattered. Where the thinning creates greater amounts of

downed woody debris, the debris would be hand-piled and burned. Within the wilderness

study area, 105 of the 825 acres were mechanically treated in 2003, thus the treatment on

these areas would involve less cutting and limbing compared to acres that have not been

previously treated. The mechanical thinning would be a one-time occurrence; no re-

treatment of the areas is planned. In addition to the mechanically treated acres, alternative 2

would also involve 12,042 acres of prescribed burning in 20 units with an associated 3 miles

of fire line in the wilderness study area (9 percent of the wilderness study area). The

prescribed burns would involve some helicopter overflights and possibly some landings,

although preference would be given to non-motorized means of personnel transport to the

extent possible.

Within the Phillips Ridge Inventoried Roadless Area, alternative 2 would include 291 acres

of mechanical fuel treatment (2.9 percent of the area). Specific treatment units include

portions of Phillips Bench Units 1, 2, 5, and 7. Proposed treatment in units 1, 2, and 7

would be noncommercial thinning, hand-pile and burning without any use of ground-based

machinery (i.e. same treatment as described for the wilderness study area). Unit 5 could

include commercial thinning with machine-cutting or machinery use for piling material.

Only 3.6 percent (7 acres) of treatment unit 5 is located within the Phillips Ridge Inventoried

Roadless Area; the estimated amount of timber that would be removed and sold is 0.2 MBF.

Portions of the power line road accessing Phillips Bench Unit 5 are located within the

inventoried roadless area according to GIS map overlays. To access this unit, 1.5 miles of

the road within the inventoried roadless area would need maintenance work. This work

would involve blading, drainage, and some widening necessary to make the road suitable

for log trucks per the approved maintenance level 2 standards. The maintenance level of the

road would not be changed. Alternative 2 would also include 3,013 acres of prescribed

burning in two units within the Phillips Ridge Inventoried Roadless Area with an associated

1.07 miles of fire line (30 percent of the area)

Within the Munger Mountain Inventoried Roadless Area, no mechanical fuel treatment

would occur. Treatment in this inventoried roadless area would only involve prescribed


16

burning totaling 3,844 acres in two units with an associated 4.24 miles of constructed fire

line (30 percent of the area). There would be no road work.

Direct and Indirect Effects


Effect on potential for future designation as Wilderness: Implementing alternative 2 would

have little effect on the area’s potential for future designation as wilderness for the reasons

discussed under alternative 1.

Implementing alternative 2 would not create any roads, clearcuts, or other physical

improvements that disqualify the area from consideration as wilderness. The inventory

criteria state that vegetation treatments should be “substantially unnoticeable” when

considering the area as a whole. The post-treatment canopy closure would be similar to the

surrounding uncut area and thinning operations would occur only in certain locations along the

boundary, thus the proposed mechanical treatments would not likely be viewed as affecting the

area as a whole. Additionally, because the area is Congressionally designated as a study area, it

must be included in the inventory of lands evaluated for potential wilderness designation.

During the evaluation phase, the interdisciplinary review would evaluate the degree to which

the area may be managed to preserve wilderness characteristics including consideration of

adjacent land management. The fact that the area where treatments are proposed is part of the

wildland-urban interface area would clearly be part of this evaluation. However, consideration

of adjacent lands would be evaluation factor whether or not any vegetation treatments are

implemented. If, over time, more lightning-ignited fires were allowed to burn with less human

interference, there would be a small improvement in evaluating the degree to which the area

generally appears to be affected primarily by the forces of nature.

Effect on “presently existing wilderness character”: In comparison with other alternatives,

alternative 2 would have the greatest effect on “presently existing wilderness character.” In

the short term (1- 3 years), there would be a decline in the untrammeled quality, a decline in

the natural quality on the acres where mechanical treatment occur, a temporary decline in

the undeveloped quality, and a slight temporary decline in the opportunity for solitude or

primitive and unconfined recreation. However, in the long term (20 years or longer), there

would be some improvement in both the untrammeled and natural quality and no effect on

the undeveloped and solitude qualities. This alternative would do the most to reduce the risk

of fire escaping from the wilderness study area and give fire managers a higher probability

of success in controlling fire with less use of heavy-handed suppression actions. Against a

baseline condition of 100 percent suppression in 1984, the ability to respond to natural fire

starts with less human interference would have positive benefits to the untrammeled and

natural aspects of wilderness character, although the magnitude of the improvement is

unknown. Information to support the findings on effect to wilderness character is provided

below.

Untrammeled Quality: There would be up to a 3-year decline in the untrammeled quality due

to the decision to manipulate fuels. However, in the long term, managers would be able to

manage more fires using lighter-hand suppression tactics and would be able to allow more

fires to burn naturally. In contrast to the small scale mechanical treatments implemented in


17

2003, the proposed treatments are considered large enough to effectively change how fires

are managed post-treatment. The improvement in how natural fires are managed is due to

the expected reduction in flame length and potential for crown fire. Within the defense zone,

there would be a 35 percent reduction in the area capable of producing 4 foot flame lengths

and a 65 percent reduction in the area capable of producing active crown fire (refer to Fire

and Fuels analysis in this chapter). In comparison with the 100 percent fire suppression that

existed in 1984, the treatments would result in fewer trammeling actions and less

suppression actions, especially for fires that ignite later in the season. However, some

trammeling would still occur since, even with the treatments, some fires would have to be

suppressed. Given the multitude of context-specific factors that go into deciding how an

individual fire is managed, it is not possible to predict how many fewer trammeling actions

would occur post-treatment, thus the magnitude of the improvement is unknown.

Natural Quality: Alternative 2 would result in a decline in the natural quality in localized

areas where treatments would occur. In the short term, plant community species

composition and age structure would be altered on 825 acres by removing smaller diameter

trees, especially subalpine fire. Fire line construction associated with prescribed burning is

anticipated to have less impact on natural conditions compared with fire line construction

associated with suppression action because there is greater control in determining where and

when to ignite prescribed burns and more ability to use naturally occurring fuel breaks. This,

combined with the standard use of minimum impact suppression techniques, means fire lines

are unlikely to be noticeable after one year. Monitoring conducted on the Jackson Ranger

District one year after large fires in the Gros Ventre Wilderness support the conclusion that

fire line impacts are minimal (USDA 2011). In the long term, the natural quality would be

enhanced considering the area as a whole since natural fires would be allowed to play a greater

role in shaping plant communities and associated wildlife diversity. However, as noted for the

untrammeled quality, the magnitude of this improvement is unknown due to the multitude of context-

specific factors that go into decisions about managing individual fires.

Undeveloped quality: There would be a temporary short-term decline in the undeveloped

quality due to an increase in the use of chainsaws. Based on past fuel crew efforts, an

estimated 3-5 acres can be treated per day. Thus, for 825 acres, an estimated 206 total days

of chainsaw use would occur while the project was being implemented. This effect would

be spread over a 2 to 3 year period. Additionally, the prescribed burns may require a few

helicopter landings. Helicopter use would be sporadic, occurring only when conditions are

conducive to burning, either in the spring or fall. Once the thinning operation and prescribed

burns ceased, there would be no effect on the undeveloped quality.

Solitude quality: There would be a slight temporary short-term decline in the opportunity

for solitude or primitive and unconfined recreation due to the presence of fire crews and

need for temporary closures. Since much of the mechanical thinning work is not expected

to occur around trails, it is unlikely that this use would negatively affect visitor’s

opportunity to experience solitude. However, during prescribed fire operations, some trail

or area closures may be necessary which would temporarily affect visitor opportunities.

This effect would be minimized through mitigation measures that provide for adequate

public notification prior to burning. Once fuel treatment operations ceased, there would be

no effect on this quality.


18


Alternative 2 would have no adverse effect and some beneficial effect on apparent

naturalness and natural integrity in the Munger Mountain Inventoried Roadless Area since

there would be no disturbance from mechanical treatments and the prescribed burns would

enhance natural integrity in the long-term. Within the Phillips Ridge Inventoried Roadless

Area, alternative 2 would have some adverse effect on apparent naturalness in the short-term

due to disturbance from mechanical fuel treatments (affecting approximately 2.9 percent of

the inventoried roadless area). However, natural integrity would be enhanced in the long-term

due to the ability to manage future fires with less human interference and more minimum

impact suppression tactics.

Within both inventoried roadless areas, there would be no effect on remoteness and solitude.

With both areas, there would be a temporary short-term effect on primitive and unconfined

recreation where trail or area closures would be necessary during burning operations. This

effect would be minimized due to project design features that require adequate public

notification prior to burning. Within the Phillips Inventoried Roadless Area, there is some

potential for adverse effect on primitive and unconfined recreation if mechanical fuel

treatments open up the forest enough to allow motor vehicle to travel off- road. This

unauthorized use would be minimized due to the design feature that states: “roadside

openings created by treatments in the vicinity of known non-system routes would be

physically blocked”. Implementation of this design feature would require careful oversight

to ensure effectiveness.

Cumulative Effects

Based on an examination of past, present and reasonably foreseeable projects listed in

appendix E, the combination of acres proposed for mechanical treatment under this project

plus the acres that were mechanically treated as part of the 2003 Red Top Meadows fuel

treatment project that are not part of the present project would result in a total of 861 acres

of the wilderness study area manipulated by mechanical thinning if alternative 2 were

implemented, amplifying the effect on the untrammeled quality. There are no cumulative

effects associated with the proposed prescribed burns since prescribed burning has not

occurred in the past and are there no reasonable foreseeable projects planned for the future

within the wilderness study area or inventoried roadless areas beyond the current Teton to

Snake project. Commenters on the Teton to Snake fuel project expressed concern about on-

going recreation activities within the WSA, notably snowmobiling, heli-skiing and

mountain biking. However, the proposed Teton to Snake fuel project would have no direct

or indirect effect on the amount or type of recreation occurring in the WSA, therefore there

are no cumulative effects. Analyzing the effect of recreation activities on the character of

the WSA is a separate question which is beyond the scope of this project.

Alternative 3 – Reduce Potential Impacts to Special Areas and Wildlife Habitat Under alternative 3, there would be 391 acres of mechanical fuel treatment in the Palisades

Wilderness Study Area (0.3 percent of the area). In comparison with alternative 2,

Recreation Trail Units 6 and 7, Trails End Unit, and Red Top Unit 3 would be eliminated

and acres for the other treatment units would be reduced. Like alternative 2, all of the


19

proposed treatments within the wilderness study area would be noncommercial thinning and

would consist of cutting smaller trees (under 9 inches dbh) and limbing branches on larger

trees to reduce the potential of fire spreading into tree crowns. Chainsaws would be used for

cutting but no ground-based machinery would be used. No permanent or temporary roads

would be constructed or reconstructed. Material would be scattered or hand-piled and

burned. Within the wilderness study area, 96.5 of the acres were previously treated in 2003,

thus the treatment on these acres would involve less cutting and limbing compared to acres

that have not been treated. The mechanical thinning would be a one-time occurrence; no re-

treatment of the areas is planned. In addition to the mechanically treated acres, alternative 3

would involve 7,910 acres of prescribed burning in 11 units with an associated 1.6 miles of

fire line (6 percent of the area).

Within the Phillips Ridge Inventoried Roadless Area, alternative 3 would include 273 acres

of mechanical fuel treatment (2.8 percent of the area). Specific treatment units include

portions of Phillips Bench Units 1, 2, 5 and 7. Unlike alternative 2, all treatments within the

inventoried roadless area under alternative 3 would be noncommercial thinning, hand-pile

and burning without any use of ground-based machinery.

No timber would be removed from the inventoried roadless area and sold. Portions of the

power line road would still require maintenance, however the portion of road within the

inventoried roadless area would be reduced to 0.4 miles of maintenance under this

alternative. Alternative 3 would also include 2,432 acres of prescribed burning in two units

within the Phillips Ridge Inventoried Roadless Area with an associated 1.07 miles of fire

line (25 percent of the area).

Within the Munger Mountain Inventoried Roadless Area, no mechanical fuel treatment

would occur. Treatment in this inventoried roadless area would just involve prescribed

burning totaling 1,658 acres in one unit (Munger Mountain burn unit 2 is eliminated under

alternative 3) with an associated 2.92 miles of fire line (13 percent of the area).

Direct and Indirect Effects


Effect on potential for future designation as Wilderness: Implementing alternative 3 would

have little effect on the area’s potential for future designation as wilderness for the reasons

discussed under alternative 1 and 2. The area would still be eligible for consideration as

Wilderness and evaluation of the effect of designation on adjacent lands would occur whether

or not fuel treatments were implemented.

Effect on “presently existing wilderness character”: Alternative 3 would have less effect

on “presently existing wilderness character” compared with alternative 2. In particular, there

would be less short-term effect on the natural quality and less effect on the undeveloped

quality and the opportunity for solitude due to the fewer number of acres treated under this

alternative. However, the effect on the untrammeled quality would be similar to alternative 2

since fuel treatments still represent an intentional decision to manipulate fuels. However, like

alternative 2, in the long term, there would be some improvement in both the untrammeled

and natural quality and no effect on the undeveloped and solitude qualities. This alternative

would still reduce the risk of fire escaping from the WSA and give fire managers a higher


20

probability of success in controlling fire with less use of heavy-handed suppression actions,

although the probability of success would be somewhat less than under alternative 2. Against

a baseline condition of 100 percent suppression in 1984, the ability to respond to natural fire

starts with less human interference would have positive benefits to the untrammeled and

natural aspects of wilderness character, although the magnitude of the improvement is

unknown. Information to support the findings on effect to wilderness character is provided

below.

Untrammeled Quality: There would be up to a 3-year decline in the untrammeled quality

due to the decision to manipulate fuels. However, in the long term, managers would be able

to manage more fires using lighter-hand suppression tactics and would be able to allow

more fires to burn naturally. The improvement in how natural fires are managed is due to

the expected reduction in flame length and potential for crown fire. Within the defense zone,

there would be a 20 percent reduction in the area capable of producing 4 foot flame lengths

and a 41 percent reduction in the area capable of producing active crown fire (refer to Fire

and Fuels analysis in this chapter). In comparison with the 100 percent fire suppression that

existed in 1984, the treatments would result in fewer trammeling actions and less

suppression actions, especially for fires that ignite later in the season. However, some

trammeling would still occur since, even with the treatments, some fires would have to be

suppressed. Given the multitude of context-specific factors that go into deciding how an

individual fire is managed, it is not possible to predict how many fewer trammeling actions

would occur post-treatment, thus the magnitude of the improvement is unknown.

Natural Quality: Alternative 3 would result in a decline in the natural quality in localized

areas where treatments would occur. In the short term, plant community species

composition and age structure would be altered on 391 acres (434 fewer acres than

proposed under alternative 2). Like alternative 2, the standard use of minimum impact

suppression tactics for fire line construction combined with the ability to control where and

when prescribed burns occur means that fire line effects are unlikely to be noticeable after

one year. In the long term, the natural quality would be enhanced considering the area as a

whole since natural fires would be allowed to play a greater role in shaping plant

communities and associated wildlife diversity. However, as noted for the untrammeled quality, the

magnitude of this improvement is unknown due to the multitude of context-specific factors that go into

decisions about managing individual fires.

Undeveloped quality: There would be a temporary short-term decline in the undeveloped

quality due to an increase in the use of chainsaws. Based on past fuel crew efforts, an

estimated 3-5 acres can be treated per day. Thus, for 391 acres, an estimated 98 total days of

chainsaw use would occur while the project was being implemented. This effect would be

spread over a 2 to 3 year period. Additionally, the prescribed burns may require a few

helicopter landings. Helicopter use would be sporadic, occurring only when conditions are

conducive to burning, either in the spring or fall. Once the thinning operation and prescribed

burns ceased, there would be no effect on the undeveloped quality.

Solitude quality: There would be a slight temporary short-term decline in the opportunity

for solitude or primitive and unconfined recreation due to the presence of fire crews and

need for temporary closures. Since much of the mechanical thinning work is not expected

to occur around trails, it is unlikely that this use would negatively affect visitor’s


21

opportunity to experience solitude. However, during prescribed fire operations, some trail

or area closures may be necessary which would temporarily affect visitor opportunities.

This effect would be minimized through mitigation measures that provide for adequate

public notification prior to burning. Once fuel treatment operations ceased, there would be

no effect on this quality.


Alternative 3 would have no adverse effect and some beneficial effect on apparent

naturalness and natural integrity attributes in the Munger Mountain Inventoried Roadless

Area since there would be no disturbance from mechanical treatments and the proposed

prescribed burning would serve to enhance natural integrity and manageability in the long-

term. Within the Phillips Ridge Inventoried Roadless Area, alternative 3 would have some

adverse effect on apparent naturalness in the short term but this effect would be less than

under alternative 2 due to the reduced amount of disturbance. Natural integrity and

manageability would still be enhanced in the long-term under alternative 3.

Within both inventoried roadless areas, there would be no effect on remoteness and solitude

and no effect on special features. Within both areas, there would be a temporary short-term

effect on primitive and unconfined recreation where trail or area closures were necessary

during burning operations but this effect would be minimal due to project design features

that require adequate public notification prior to burning. Within the Phillips Inventoried

Roadless Area, there is some potential for adverse effects on primitive and unconfined

recreation if mechanical fuel treatments open up the forest enough to allow motor vehicle to

travel off-road, however the lack of ground-based machinery would help minimize this

effect. This unauthorized use would be minimized due to the design feature that states:

“roadside openings created by treatments in the vicinity of known non-system routes would

be physically blocked”. Implementation of this design feature would require careful

oversight to ensure effectiveness.

Cumulative Effects

Based on an examination of past, present and reasonably foreseeable projects listed in

appendix E, the combination of acres proposed for mechanical treatment under this project

plus the acres that were mechanically treated as part of the 2003 Red Top Meadows fuel

treatment project that are not part of the present project would result in a total of 443 acres

of the wilderness study area manipulated by mechanical thinning if alternative 3 were

implemented, amplifying the effect on the untrammeled quality. There are no cumulative

effects associated with the proposed prescribed burns since prescribed burning has not

occurred in the past and are there no reasonable foreseeable projects planned for the future

within the wilderness study area or inventoried roadless areas beyond the current Teton to

Snake project. The proposed Teton to Snake fuel project would have no direct or indirect

effect on the amount or type of recreation occurring in the WSA, therefore there are no

cumulative effects. Analyzing the effect of recreation activities on the character of the WSA

is a separate question which is beyond the scope of this project.


22

Effects Common to All Action Alternatives The Jedediah Smith Wilderness is located adjacent to the Phillips Ridge IRA and is a Class II airshed. There would be no direct effects from the proposed treatments on the Wilderness however indirect effects due to smoke may affect visibility during burning operations. Due to prevailing southwest winds, smoke would primarily be directed away from the Jedediah Smith Wilderness, minimizing the effect on wilderness visitors. The designated Wild and Scenic Snake River is also located adjacent to the project area but none of the proposed treatments are within the ¼ mile interim boundary for the wild and scenic river corridor. The closest treatments are the proposed burn units within the Munger Mountain IRA. These treatments would not directly affect the river’s free-flow, water quality, or outstandingly remarkable values, however they would be visible from the river.

E. Recommended Mitigation Measures Refer to Project Design Features document

F. Monitoring Recommendations Percent of wildfire starts allowed to play their natural role in the ecosystem and the

amount of acres burned within the project area.

Change in suppression tactics by tracking the following items; number of helispots,

miles of line constructed and the use of mechanical equipment within the Palisades

WSA (BTNF portion).


23

G. Effects Summary

Table 1. Comparison of alternative effects on Palisades Wilderness Study Area

Alternative 1

No Action Alternative 2 Alternative 3

Acres of mechanical fuel treatment including new acres compared to 2003 treatment

0 acres

825 acres

(approx. 721 new treatment acres and 104 re-treatment acres)

391 acres

(approx. 294 new treatment acres and 97 re- treatment acres)

Acres of prescribed burning including miles of fire-line

0 acres

12,042 acres

(3.0 miles of fire line)

7,910 acres


Effect on potential for inclusion in the National Wilderness Preservation System

No effect

Little effect

Little effect

Effect on “presently existing wilderness character”

No effect in short term; increasing decline in untrammeled and natural quality over long term due to cumulative fire suppression actions.

Short-term decline. In long-term, the untrammeled and natural quality would improve and there would be no effect on other qualities. However, the magnitude of the improvement is unknown.

Short-term decline but less impact on natural and undeveloped quality than under alternative 2 due to fewer acres treated. In long-term the untrammeled and natural quality would improve and there would be no effect on other qualities. However, the magnitude of the improvement is unknown.

Table 2. Comparison of alternative effects on Inventoried Roadless Areas

Alternative 1

No Action Alternative 2 Alternative 3

Acres of mechanical fuel treatment

0 acres

291 acres

(all in Phillips Inventoried Roadless Area)

273 acres

(all in Phillips Inventoried Roadless Area)

Acres of prescribing burning including miles of fireline

0 acres

6,857 acres

(in both inventoried roadless areas)


4,090 acres

(in both inventoried roadless areas)


Miles of road work

0 miles

1.5 miles (Phillips Inventoried Roadless Area)

(All maintenance)

0.4 miles (Phillips Inventoried Roadless Area)

(All maintenance)

Amount of commercial timber cut

0 board feet 0.2 MBF 0 MBF


24

Effect on wilderness attributes

No effect in short-term, increasing effect on natural integrity in long term

Beneficial effect on natural integrity in Munger Mountain Inventoried Roadless Area: some adverse effect on apparent naturalness in Phillips Ridge Inventoried Roadless Area in the short term (2.9 percent of area)

Beneficial effect on natural integrity in Munger Mountain Inventoried Roadless Area; some adverse effect on apparent naturalness in Phillips Ridge Inventoried Roadless Area in the short term (2.8 percent of the area but no use of ground-based machinery).

Compliance with Forest Plan and Other Relevant Laws, Regulations, Policies and Plans

Implementing mechanical treatments under alternative 2 and 3 may not meet the Wyoming

Wilderness Act’s direction to maintain “presently existing wilderness character” within the

wilderness study area in the short term and may not meet Forest Plan direction for the

Wilderness Study Area. Implementing the no-action alternative would comply with the

Wyoming Wilderness Act and Forest Plan. Design features would need to be effectively

implemented and monitored.

Unavoidable Adverse Effects

There would be an unavoidable short-term adverse effect on some aspects of wilderness

character during the fuel treatment operations. Wilderness character would improve in the

long term because there would be less fire suppression and an increased ability to use light-

hand tactics when fires must be suppressed but the magnitude of this improvement is

unknown.

H. References

Government Accounting Office. 1993. Status and Uses of Wilderness Study Areas. Report to

the Chairman, Subcommittee on National Parks, Forests, and Public Lands, Committee on

Natural Resources. House of Representatives. GAO/RCED – 93-151. 104 p.

Landres, P. Barns, C. Boutcher, S. et. al. 2015. Keeping it wild 2: an updated interagency

strategy to monitor trends in wilderness character across the National Wilderness

Preservation System. Gen. Tech. Rep. RMRS-GTR-340. Fort Collins, CO: USDA, Forest

Service, Rocky Mountain Research Station. 114 p.

Miller, C. 2011. The hidden consequences of fire suppression. Park Science. Vol. 28. No. 3.

Riginos, C. and M. Newcomb. 2015. The Coming Climate: ecological and Economic

Impacts of Climate Change on Teton County. A study by the Charture Institute and the

Teton Research Institute of Teton Science Schools. Unpublished document, Jackson, WY


25

Rojo, A. 2012. An Analysis of Non-Suppression Management Strategies of Unplanned

Wildland Fire in the Palisades Wilderness Study Area. Unpublished paper submitted in

partial fulfillment of the requirements for TFM 26. Available at the BTNF, Jackson Ranger

District, Jackson, WY

USDA Forest Service 2008. Suggestions for analyzing the effects to wilderness potential

from project activities within Inventoried Roadless Areas. Unpublished document. Forest

Service Intermountain Region. Randy Welsh, Wilderness specialist.

USDA Forest Service, Bridger-Teton National Forest. 2011. Bull Fire Monitoring Report.

Unpublished document. Jackson Ranger District. Jackson, WY.

Westerling, A.L., Turner, M.G. Smithwick, E.A., Romme, W.H. and Ryan, M.G. 2011.

Continued warming could transform Greater Yellowstone fire regimes by mid-21st century.

Proceedings of the National Academy of Sciences, 108. 13165-13170.

Map 1. Palisades WSA

Map 2. Past Timber harvest within or near Palisades WSA

Units within WSA

Units within WSA

Map 3. Munger Mountain Inventoried Roadless Area

Map 4. Phillips Ridge Inventoried Roadless Area

Map 5. Historic Fires since 1931 (Rojo 2012)

Note that within the Palisades WSA, there have only been two fires that burned more than 50 acres since the 1950s – Mosquito Creek and Green Knoll. Most of the past fire occurrence happened in the 1930s

Map 6. Modeled fire occurrence under low severity conditions if fires had been allowed to burn (50th percentile burning index) (Rojo 2012)

Map 7. Dozer line constructed during Green Knoll fire

Teton to Snake Fuels Management Projecta123.g.akamai.net/7/123/11558/abc123/forestservic... ·...

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